Imperium Executive Search

Legal

Code of Practice

Last updated: 29 June 2026

Imperium Executive Search Limited is an executive search company focused on senior leadership, executive, board-level and specialist appointments across infrastructure, engineering, construction, real estate, energy, utilities, transport and related markets, operating on a retained basis. Our role is to help clients identify, attract, assess and engage high-calibre talent while treating candidates, clients and business contacts with professionalism, confidentiality, fairness and respect. This Code of Practice sets out the standards we aim to follow in all executive search, candidate engagement, client representation and recruitment activity.

01

Our Guiding Principles

We are committed to: acting with integrity and professionalism; treating candidates and clients fairly; protecting confidential information; complying with applicable recruitment, data protection and anti-discrimination laws; presenting candidate information accurately and responsibly; avoiding misleading statements; respecting candidate choice and confidentiality; maintaining clear terms of business with clients; and supporting ethical and transparent recruitment practice.

02

Candidate Confidentiality

Candidate confidentiality is central to our work. We will not knowingly submit an identifiable candidate CV, profile or personal details to a client for a specific role unless we have taken reasonable steps to confirm that the candidate is aware of the opportunity and has authorised us to represent them for that role or client. Where a client's identity has not yet been disclosed to a candidate, we may share anonymised or non-identifiable candidate information with the client to assess potential suitability. We will only share candidate information that is relevant and necessary for the recruitment process.

03

Candidate Engagement

When engaging with candidates, we will aim to: explain who we are and why we are contacting them; provide relevant information about the opportunity where possible; respect confidentiality and sensitivity around career discussions; give candidates the opportunity to opt out of further contact; avoid pressuring candidates into discussions or processes; keep candidate information accurate and up to date where possible; and make reasonable efforts to communicate clearly and professionally. Candidates may ask us to update, correct or remove their information, subject to any legal or legitimate business reason for retaining limited records.

04

No Fees to Candidates

Imperium Executive Search Limited does not charge candidates for work-finding services. Our fees are charged to clients in accordance with our agreed terms of business. Candidates should not pay any fee to be considered for a role introduced by Imperium.

05

Client Representation

When working with clients, we will aim to: understand the role, organisation, reporting lines, expectations and appointment criteria; agree commercial terms before submitting candidates wherever possible; provide accurate and relevant candidate information; highlight known material information relevant to candidate suitability; protect candidate confidentiality; avoid exaggerated or misleading claims; and maintain professional communication throughout the process. Clients are responsible for final hiring decisions and for carrying out appropriate right-to-work, reference, qualification, professional membership, medical, criminal record, regulatory or other statutory checks unless expressly agreed otherwise in writing.

06

Candidate Suitability

We take reasonable care when assessing candidate suitability. This may include reviewing career history, experience, skills, qualifications, professional background, market reputation and candidate motivation. However, clients remain responsible for conducting their own due diligence before making an offer or appointment. This includes verifying identity, right to work, references, qualifications, professional registrations, medical fitness, criminal record checks and any sector-specific requirements.

07

Data Protection and Privacy

We process candidate, client and business contact data in accordance with UK data protection law and our Privacy Policy. We will aim to ensure that personal data is: processed lawfully, fairly and transparently; collected for clear recruitment, executive search, business development or contractual purposes; limited to what is relevant and necessary; kept accurate where possible; retained only for as long as necessary; and protected against unauthorised access, disclosure, loss or misuse.

08

Client and Candidate Data Sharing

Candidate information supplied to clients is confidential and must only be used for considering the candidate for the agreed role or search assignment. Clients must not copy, forward, disclose, distribute or use candidate information for any other purpose without appropriate authority and a lawful basis. Where candidate information is shared with client group companies, affiliates, local employment partners or third-party advisers, the client is expected to ensure that such recipients protect the information and comply with applicable confidentiality and data protection obligations.

09

Equality, Diversity and Non-Discrimination

We are committed to fair and responsible search practice. We will not knowingly discriminate against candidates on the grounds of age, disability, gender reassignment, marriage or civil partnership, pregnancy or maternity, race, religion or belief, sex, sexual orientation or any other protected characteristic. We will aim to assess candidates based on relevant skills, experience, qualifications, leadership capability, cultural contribution, track record and suitability for the role. We encourage clients to use fair, objective and proportionate selection criteria.

10

Reasonable Adjustments

Where a candidate tells us they require reasonable adjustments during a recruitment process, we will take reasonable steps to support the request and, where appropriate, discuss it with the client with the candidate's knowledge.

11

Social Media and Public Information

As an executive search firm, we may use professional networking platforms, public company information, industry publications, public profiles and other lawful sources to identify and approach potential candidates. We will avoid intrusive or irrelevant personal social media checks unless such checks are necessary, proportionate, role-specific and transparent. Information found online may be incomplete, outdated or inaccurate. We will take reasonable care before relying on such information in a recruitment process.

12

Automated Decision-Making

We do not make solely automated recruitment decisions about candidates. Any decision to approach, progress, shortlist or submit a candidate involves human judgement. If we introduce automated decision-making or profiling tools that significantly affect candidates, we will review our legal obligations and update our policies accordingly.

13

Confidentiality and Non-Disclosure

We treat client assignments, candidate details, remuneration information, business plans, leadership changes, succession matters and search activity as confidential. We expect clients, candidates, suppliers and partners to treat information shared by Imperium with the same level of confidentiality. Confidential candidate information must not be used to circumvent Imperium's introduction, representation or fee arrangements.

14

Conflicts of Interest

Where we become aware of an actual or potential conflict of interest, we will take reasonable steps to manage it appropriately. This may include disclosure to relevant parties, internal restrictions, declining an assignment or agreeing specific off-limit arrangements with a client.

15

Anti-Bribery, Corruption and Improper Conduct

We do not tolerate bribery, corruption, improper inducements or unethical conduct. We will not knowingly offer, request or accept any improper payment, gift, favour or advantage in connection with a recruitment process.

16

International Assignments

Where recruitment activity involves international clients, candidates, group companies or local employment partners, we will aim to ensure that confidentiality, candidate consent and authority, data protection and commercial terms are addressed appropriately. Clients using local partners, subsidiaries or affiliates to employ a candidate introduced by Imperium remain responsible for ensuring that candidate information is protected and that all legal, employment and contractual obligations are met.

17

Complaints

If a candidate, client or business contact has a complaint about our conduct, they should contact us in writing at [email protected]. We will review complaints fairly and aim to respond within a reasonable timeframe.

18

Review of This Code

We may update this Code of Practice from time to time to reflect changes in our business, legal obligations or professional standards. The latest version will be published on our website.

For any complaints or enquiries regarding our conduct, please contact [email protected]